- Case Summary

University / Undergraduate
Modified: 4th Jun 2001
Wordcount: 601 words


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Legal Case Summary

Summary: A case that expands upon the concept of 'make whole' relief under Title VII.


In the Pollard v. DuPont case, Pollard (petitioner) was an employee of DuPont (respondent) who filed a lawsuit claiming sexual harassment. Pollard claimed that co-employees and supervisors at DuPont's Tennessee plant harassed her verbally and physically. DuPont's management addressed the situation, which resulted in the cessation of the conduct; however, Pollard suffered serious psychological damage.

Upon her return to work, Pollard requested a change in job due to the severe psychological damage but DuPont denied this request, forcing her to leave the job. Pollard then filed a lawsuit under Title VII of the Civil Rights Act of 1964, claiming sexual harassment and constructive dismissal.


The key issue under consideration in Pollard v. DuPont was whether the concept of 'make whole' relief provided under Title VII includes the award of front pay ('front pay' refers to future loss of earnings as a result of the discriminatory conduct). The courts had previously held that front pay could be awarded but its limits were an issue in contention.

The case also questioned whether the trial court’s denial of Pollard’s request for front pay because it found that the reassignment she had sought was not 'constructively available' was a valid reason.


The Pollard v. DuPont case is significant in that it expands the concept of 'make whole' relief under Title VII and broadens the scope of remedies available to victims of discriminatory practices in the workplace. Although the decision was unanimous, it did invite discussion about the exact nature and limitations of front pay. It signified that courts could award front pay as a remedy for discriminatory dismissal, even without any specific employment position being available. Essentially, the case enforced the idea that laws preventing workplace discrimination have a reparative, as well as preventive, function.


The Supreme Court, through Justice Anthony Kennedy, reversed and remanded the lower court's decision. In a unanimous decision, the Court held that front pay is indeed part of the 'make whole' relief provided under Title VII and that its award is not limited by the account of a particular job being available. The court concluded that front pay constitutes part of the legal remedies provided for under Title VII and thus is an appropriate tool for relieving victims of discriminatory practices.


  • Pollard v. E.I. du Pont de Nemours & Co., 532 U.S. 843 (2001)
  • Title VII of the Civil Rights Act of 1964

Journalist Brief

In simple terms, the Pollard v. DuPont case is about a woman who was sexually harassed at work and claimed for her future loss of earnings as a result (known as 'front pay'). The Supreme Court unanimously decided that front pay should indeed be considered a possible avenue for relief under the laws that combat workplace discrimination.


What was the main issue in Pollard v. DuPont?

Answer: The main issue was whether 'front pay' should be considered an appropriate relief under Title VII in cases of workplace discrimination.

What was the Supreme Court's verdict?

Answer: The Supreme Court held that front pay is indeed part of the 'make whole' relief under Title VII.

What is the significance of this case for workplace discrimination cases?

Answer: This case broadened the scope of remedies for victims of discriminatory practices by including front pay as a valid form of relief, even without any specific position being available for reassignment.

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